Part two of three. Thoughts on the TCFD reports that the largest UK pension schemes have prepared.
Welcome back to our guide to the experiences of schemes that published Task Force on Climate-Related Financial Disclosures (TCFD) reports in 2022.
In part one, Governance is king, we outlined some of the key findings from TPR’s review, along with more detail on the governance aspects of the reports.
In this part (part two), we will dive deeper into the reports' often-complex strategy, scenario analysis and risk management sections.
In part three, we will discuss the metrics and targets section of the reports before concluding and setting out what we think schemes of all sizes should do next.
Trustee boards often use scenario analysis to help them understand the risks associated with different decisions, such as investment strategy. However, very few had considered the potential path of their scheme’s funding under potential future scenarios for the world’s climate until preparing their first TCFD reports. As a result, most trustee boards had a lot to get their heads around, and this was reflected in the varied feedback from TPR from their review. For example, TPR noted that many schemes missed information required by the legislation, including the impact of climate-related risks on the scheme’s investment and funding strategy, rather than simply on asset and liability values.
“Whilst scenario analysis can highlight potential outcomes, it cannot illustrate the full range of possibilities.”
James Wintle | Managing Director, Retirement
Although it was encouraging to see that most schemes opted for quantitative analysis (rather than qualitative), there is still more that schemes can do to take things further. Rather than just considering the impact on the assets and liabilities of the scheme under chosen scenarios, TPR pointed out that this could helpfully be extended to consider how the results might impact scheme’s investment or funding strategy. With so many different climate scenarios available for trustees to choose from, TPR also noted that it would be more helpful for users of the reports if each trustee board chose a single set of scenarios for their scheme to cover all aspects of the analysis in their report (e.g. assets, liabilities, covenant) to ensure a coherent story could be told.
TPR commented that this section of many of the TCFD reports that they reviewed was shorter than others and appeared designed to meet the minimum requirements only. This may well be because the schemes will have already had risk management structures in place that climate-related risks were then embedded in. However, it is important that schemes detail the processes they have in place to identify, assess and manage risks in their TCFD reports, rather than simply listing the risks that have been identified.
Additionally, TPR noted that it would be useful to provide specific examples of actions that trustees took over the year to manage the risks they identified. For example, did they (or someone on their behalf) engage with companies known to be big polluters, or carry out a review of their investment managers where climate-related risks were part of the decision-making process?
As with the strategy section of the reports, ensuring that the employer covenant aspects are captured appropriately in this process is also key and underlines the importance of allowing plenty of time to prepare a TCFD report, given the range of inputs and considerations required. Further guidance to come on employer covenant considerations will be helpful for schemes in giving this area greater attention.
The results of scenario analysis have generated healthy discussion and debate amongst many trustee boards, whom we have seen be fully engaged in the process of assessing the potential impact of climate on their scheme’s assets and liabilities. Ensuring that the impact on the employer covenant is incorporated fully into this analysis and using the research to support strategic decisions are the next steps for many trustee boards.
Part three of this series covers metrics and targets before wrapping up and outlining the next steps for trustees. Read more now.